Search

Question of the Week: Calculating Generator Status

Posted on 1/21/2011 by James Griffin

Q. What is "generator status," and how do I calculate it?

A. Each and every person who produces hazardous waste is a generator and must determine his or her generator status each calender month. A facility’s generator status determines how stringently it is regulated and how long it may accumulate hazardous waste on site without a permit.

Three Categories of Waste Generator

Conditionally Exempt Small Quantity Generators (CESQGs) generate no more than 100 kilograms of hazardous waste per calender month [40 CFR 261.5(a)]. CESQGs are largely exempt from regulation, as long as they classify their waste and ensure that it is recycled or disposed of in an appropriate facility.

Small Quantity Generators (SQGs) generate more than 100 kilograms but less than 1,000 kilograms of hazardous waste per calender month [40 CFR 262.34(d)]. SQGs may accumulate hazardous waste on site without a permit for up to 180 days [40 CFR 262.34(d)].

Large Quantity Generators (LQGs) generate 1,000 kilograms or more of hazardous waste per calender month. LQGs may accumulate hazardous waste on-site without a permit for up to 90 days and have more paperwork obligations than SQGs [40 CFR 262.34(a)].

Don’t Count Wastes Not Subject to Substantive Regulation

As the following waste materials are not subject to substantive regulation, they do not count when calculating generator status:
  • Hazardous waste in manufacturing process units [40 CFR 261.4(c)]
  • Hazardous waste or tractability study samples [40 CFR 261.4(d), (e), (f)]
  • Ethyl alcohol, scrap metal, or petroleum refining wastes when recycled [40 CFR 261.6(a)(3)]
  • Empty hazardous waste containers [40 CFR 261.7(a)(1)]
  • Polychlorinated biphenyl (PCB) wastes managed under TSCA [40 CFR 261.8]
  • Hazardous wastes managed immediately on site in elementary neutralization units, wastewater treatment units, or totally enclosed treatment facilities [40 CFR 261.5(c)(2)]
  • Hazardous wastes recycled immediately without prior storage in an on-site process subject to 40 CFR 261.5(c)(3)
  • Used oil, spent lead-acid batteries, and universal wastes when managed under specific regulations [40 CFR 261.5(c)(4), (5), and (6)]
  • Wastes generated in laboratory cleanouts under 40 CFR Part 262 Subpart K [40 CFR 261.5(c)(7)]
Don’t Count Your Waste Twice

Generators must count their waste at the point of generation and should not re-count the same waste during the same calender month. This means that generators should NOT count when wastes are removed from a satellite accumulation area to a central accumulation area or when wastes are shipped off site. [40 CFR 261.5(d)]

If a generator reclaims hazardous waste for reuse on site, then the product and residues from the reclamation process do not count towards the generator status, as long as the hazardous waste was counted before reclamation. If the same stock of material is continually reused, then the generator must “count” the waste once a month [40 CFR 261.5(d)].

Tags: hazardous, RCRA, waste

Find a Post

Compliance Archives

Lion - Quotes

I can take what I learned in this workshop and apply it to everyday work and relate it to my activities.

Shane Hersh

Materials Handler

We have a very busy work schedule and using Lion enables us to take the course at our own time. It makes it easy for me to schedule my employees' training.

Timothy Mertes

Hazmat Shipping Professional

You blew the doors off the competition!

Stephen Bieschke

Facilities Manager

The exercises in the DOT hazardous materials management course are especially helpful in evaluating your understanding of course information.

Morgan Bliss

Principal Industrial Hygienist

Lion's online training is more comprehensive, has better slides, and is a superior training experience than what I would get from other trainers.

Robert Brenner

District Environmental Manager

The instructor was energetic and made learning fun compared to dry instructors from other training providers.

Andy D’Amato

International Trade Compliance Manager

Much better than my previous class with another company. The Lion instructor made sense, kept me awake and made me laugh!

Marti Severs

Enterprise Safety Manager

This is a very informative training compared to others. It covers everything I expect to learn and even a lot of new things.

Quatama Jackson

Waste Management Professional

The instructor was excellent. They knew all of the material without having to read from a notepad or computer.

Gary Hartzell

Warehouse Supervisor

The instructor's energy, enthusiasm, and knowledge of the subject make the class a great learning experience!

Brian Martinez

Warehouse Operator

Download Our Latest Whitepaper

Four key considerations to help you maximize the convenience and quality of your experience with online training.

Latest Whitepaper

By submitting your phone number, you agree to receive recurring marketing and training text messages. Consent to receive text messages is not required for any purchases. Text STOP at any time to cancel. Message and data rates may apply. View our Terms & Conditions and Privacy Policy.